Site ID: 977

Object

Representation ID: 7368

Received: 20/09/2021

Respondent: St Neots Town Council

Summary of points raised:
– There is no reference to the additional services which will be provided to support the new population, assurances that it will be sufficient, or guarantees that it will be delivered.

– Projections of the impact on emergency services are not provided, projections of crime levels in the Eatons and across St Neots, and the planned policing enhancements required to meet that risk.

– Projections of the impact on the London rail link from St Neots station which is already overcrowded and causes significant problems with commuter parking on Loves Farm.

– Assumptions are made around the potential road and rail links being considered, without commentary on mitigations if those plans change
– There is no consideration to the St Neots economy or view on how the settlement will be beneficial to local businesses.
– There is also no reference to any specific steps being taken in housing planning to address the climate emergency.
– The flood risk is also not addressed, the impact of replacing green fields with concrete and tarmac and how the increased flood risk to St Neots will be mitigated.

– The area currently used by St Neots residents for dog walking, running, cycling and other recreational activity will be lost.

IMPACT ON ST. NEOTS SERVICES
Our most significant concern relates to the impact of the proposed Wyboston, Little Barford (and Tempsford) developments, the residents of which are likely to rely heavily on services provided for St Neots, Huntingdonshire and Cambridgeshire taxpayers, without contributing

financially to their provision. It seems unlikely that the needs of these new residents will be completely met by the developers of these settlements.

St Neots Town Council is concerned that the town’s schools, doctors, care facilities, recycling facilities etc will feel the effects of the new population by virtue of the fact that the town is closer than Bedford.
– Please provide details of the local facilities and assurance from Bedford Borough Council that all planned facilities will be delivered.
St Neots Town Council also requests that projections of the impacts on emergency services are also provided, in particular, community policing. St Neots local policing has been defunded and reduced over many years and is not in a position to effectively manage undesirable elements which will inevitably arrive with such an expansion in population. County Lines operations show that crime does not stay within the local area and so it’s a realistic prospect that if not properly managed in Bedfordshire that St Neots residents will feel the effects.
– Please provide emergency service impact projections, including additional detail on projected crime levels and mitigation.

ROAD AND RAIL LINKS
We acknowledge that there is an opportunity for the Wyboston development to address the long-standing issue of HGVs coming through the Eatons from Staughton Airfield, which have posed a danger to St Neots residents for many years. It is expected that the new development will give an alternative route for these lorries to take, the present objections to weight limits on Bushmead Road will be removed and the way clear for Bedford Council to take the right action.

– Please can Bedford Council confirm that this will be the case and that the long-requested weight restrictions on Bushmead Road can be implemented.
Another long-standing issue for residents of the Eatons is the lack of pedestrian access to the industrial estates near the A1/A428 roundabout. Given that this is likely to be a key employment area for residents of the Wyboston and Little Barford developments, serious consideration needs to be given to access to employment in St Neots. It is not in line with the Town Council’s declaration of a climate emergency (2019) to assume that anyone employed in this area will drive, the plan needs to include pedestrian and cyclist access to this area.

– Please provide assurance and plans to meet pedestrian requirements crossing the A1/A428 roundabout.
The most important topics under review at the moment are East-West Rail (EWR) and the A428 upgrade. The 2040 Local Plan document is unclear on:
– how either of these major infrastructure projects works with the development, especially considering uncertainty about the EWR route selection.
– what dialogue is being had between the three programs or the impact of potential changes to (or cancellation of) either transport link.
– How access from the new development to the existing St Neots station, or the potential new St Neots South station will be managed in terms of projected volumes of commuters and the handling of the additional transport burden.
– Please address all three of these points in full.

ST. NEOTS ECONOMY
It is the view of the council that it is essential that any new development brings benefit to the town and supports the growth of the local economy. Central Government and Huntingdonshire District Council are investing heavily in the high street in the coming years making the town a cultural, retail and hospitality destination in the region.

Section 5 of the plan describes the hierarchy of town centres in the area in some depth but fails to acknowledge the significant presence of St Neots Town Centre - which is significantly larger than that of any of the settlements listed with the sole exception of Bedford.
– Please provide projections of the impact and benefit to the St Neots High Street and local businesses.

CARBON NEUTRALITY
St Neots Town Council declared a climate emergency in 2019 and through various initiatives under the banner of Neot Zero, is striving to help local businesses and residents cut their carbon emissions by 2030.

While the proposed Wyboston and Little Barford developments do not fall under our jurisdiction, it is not in keeping with the spirit of the town’s objectives that new developments are built so close without reasonable facilities to ensure that all the new homes are able to be run carbon neutral.
– Please provide full details of all housing specifications that support carbon neutrality and evidence that the development will aspire in its entirety to be maintained carbon neutral or carbon negative.

FLOODING
In 2020 St Neots suffered three significant flooding events with a considerable loss of property to many residents. There is a concern that replacing farmland with hard surfaces would risk surges into the River Great Ouse and increase the flooding risk to St Neots. Locally Loves Farm and Wintringham have both been built with this in mind using balancing ponds and other measures to offset the risk, the council would like to understand more about the flooding risks identified, the potential impact to St Neots and the mitigations in place.
– Please provide a full environmental risk assessment covering St Neots.

LOSS OF RECREATION SPACE
The most noticeable immediate impact on St Neots residents will be the destruction of large swathes of the natural area which is presently enjoyed by dog walkers, runners and cyclists all year round. The public rights of way will no longer provide what our residents currently have access to, although the 2040 plan describes the importance of health and wellbeing from outdoor exercise it seems to be taking a popular facility away from those who use it today for precisely that purpose.

Presented above are the initial thoughts of the Town Council in relation to what is clearly an early document, however, we trust that the views of the council will be taken into consideration. We look forward to both your responses to our comments and being part of future consultation on the project.

Object

Representation ID: 7378

Received: 02/09/2021

Respondent: Mr Simon Goodship

Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Representation ID: 7426

Received: 20/09/2021

Respondent: Mrs Ann Spencer

I strongly object to the Dennybrook plan.
I think the Dennybrook plan would bring chaos to our local roads and our rural way of life. Several roads surrounding and leading to the site are single track roads. None of these have been scheduled for widening.
The size of Dennybrook plan would be a disaster when considering the very basic facilities we have - how long would it take for new schools, doctor's surgeries, updating of sewerage systems etc?
I am sure Dennybrook would be beneficial to St. Neots and Huntingdon Council. Bedford is becoming a ghost town and I am sure other sites such as Twinwoods would help Bedford prosper again.

Object

Representation ID: 7460

Received: 20/09/2021

Respondent: Mrs P Ball

Dennybrook

This is valuable agricultural land needed to grow our food. The A1 has not been upgraded here, no infrastructure for such a large development and all extra transport it would bring to the area. If this goes ahead, there will be nowhere to upgrade the A1.

It would overload St Neots, being nearer than Bedford.

The ideal area is adjacent to Wixams Village where there is a far better and bigger road system already there.

Object

Representation ID: 7473

Received: 21/09/2021

Respondent: TF Holdings Ltd

Comments on local plan 2040 a p/Dennybrook.
1. The plan as published is too vague for considered detailed response.
2. The proposed long-term plan for 10,000 houses on 2400 acres does not conform to government policy for the conservation of agricultural land nor the concentration of housing development to increase the use of walking and cycling within the community and thus reduce the use of motor transport.
3. There is no provision for the improvement of roads from the new development into the road and rail networks necessary for movement to and from work.
4. There is no provision for access roads for contracting vehicles necessary for the building of the new development. The existing roads are completely unsuitable for construction traffic.
5. The development of Dennybrook will tend to attract retail trade to St Neots to the detriment of Bedford.

Object

Representation ID: 7502

Received: 21/09/2021

Respondent: Mr Doug & Liz Stapleton

We would like to register our strong objection to this proposal, much of the land for which is currently high quality agricultural land. There is no element of brownfield development, which is a priority under the Government’s National Planning Policy Framework, included in this proposal, just a desire to concrete over vast amounts of agricultural land and destroy existing wildlife habitats and corridors. There are other proposals for the Local Plan rejected by the Council which include brownfield elements which should be prioritised in accordance with the Government’s Policy Framework. It is a development of over 10,000 homes covering an area from Colmworth to the A1 at Eaton Socon and Wyboston, The homes would bring with them around 20,000 extra cars, plus a considerable volume of associated delivery vehicles etc which would totally overwhelm the local road network. This proposal is hugely excessive and would totally erase a very rural area and it’s historic settlements, which would become, in effect, suburbs to a town the size of Biggleswade and two thirds the size of St Neots.

The site covers a very rural area with few access roads and minimal infrastructure. Apart from the far east end of the site near St Neots the only road access points are unclassified roads incapable of handling, and unsuitable for, heavy traffic loads or HGV’s. Several roads immediately surrounding and within the site are single-track roads and none have been scheduled for widening and given that there are many roadside nature reserves along these roads it would be difficult to widen them without destroying valuable wildlife habitats. The construction work involved for this town would create considerable disruption for neighbouring communities extending for many years, which is a totally unacceptable burden on those rural communities.

The development of this town will cause enormous damage to the local environment and biodiversity, destroying many wildlife habitats and wildlife corridors. We understand that the area is home to protected species such as Bath Asparagus, Small Eggar Moths, Sulphur Clover, Crested Cow Wheat, Red Kites, Corn Buntings. It is also home to much other wildlife and biodiversity including Badgers, Foxes, Deer, Bee Orchids, Buzzards, Tawny and Barn Owls, Egrets, Skylarks, Dragonflies and other species. Buzzards have nested in the area for a number of years and given the regularity with which they are now seen in the area, we believe that Red Kites may well be nesting in the area. Large parts of the feeding areas for Buzzards, Kites, Tawny and Barn Owls will be covered in concrete resulting in the disappearance of these magnificent birds. A friend, who is a leading expert on Owls in this country, has confirmed to us that if this development goes ahead it is inevitable that all the Tawny and Barn owls living in the area will be lost. We believe that Honeydon has by far the largest area of roadside nature reserves in the Borough which are likely to be destroyed If developers try to “improve” the local roads to make them suitable for the massive amount of additional traffic which will arrive with this crazy development. This country is now one of the most nature depleted countries in the world, ranked an abysmal 218th out of 240, thus leading the world in destroying the natural environment. Pollution levels of air, water, soil, noise, and light will also be significantly impacted. The Government are now proposing to include in their Environmental Bill a legal requirement to halt the decline in wildlife by 2030. If this proposal to build Denybrook proceeds it will not comply with that requirement in the area but will have the opposite effect of even more decline given the loss of habitats and wildlife corridors which will result.

It is very concerning that this proposal involves the loss of a considerable amount of good quality agricultural land (something like 2,400 acres I believe). Increasingly we are seeing the effects of global warming across the planet. Whilst the Government is committed to achieving considerable reductions in emissions, we are only responsible for 1% of the world’s emissions. Unless all countries, particularly the heaviest polluters, similarly commit to making considerable reductions and take urgent action to achieve those reductions, the aim to restrict global warming to 1.5 degrees will not be achieved. We think that it is highly unlikely that there will be the will to make the reductions necessary across the globe when Countries such as China, which has the highest level of emissions at 27%, a 2% increase over 2020, is committed to building large numbers of coal-fired power stations to drive it’s post-pandemic economy when if it was serious about reducing emissions, it would be closing existing ones down. The continued destruction of the Amazon rainforest, once a globally important carbon sink which absorbed more carbon dioxide than it released, has now resulted in it accounting for one billion tonnes of carbon emissions every year. With increasing rates of tree loss and in the number of fires, many of them deliberately lit to clear land, this situation is only going to get worse. It is now highly likely that our current reliance on the import of food products will be increasingly heavily affected in future years by the impact of global warming on the world and we will need to rely much more on home production, so to be planning to concrete over this amount of good quality agricultural land to meet housing needs, whilst being contrary to government policy, also seems to be verging on insanity.

There are 5 watercourses which feed into the Ouse just upstream of St Neots from the Denybrook area. These are all known to flood and St Neots has flooded many times in recent years, including most recently earlier this year. The concreting over of this area will obviously make this situation much worse as it is very likely that we will see increasingly more regular heavy rainfalls causing flash floods. There are no main sewers serving the area and also no bus services in the area. In my view it is unlikely to significantly benefit Bedford Town centre, which now appears to be in serious decline, given its close location to St Neots and the fact that by the time it is built there will be easy mainly dual carriageway access to Cambridge and Milton Keynes,

The building of this amount of houses with a population of probably 30,000 plus will have a considerable impact on health and emergency services in the area, hospitals, doctors, dentists, ambulances, fire services and police. The health service now has considerable problems and is working under considerable pressure as a result of the pressures on services caused by the pandemic and resulting in considerably increased waiting lists for many services.

The people in the rural areas affected by this proposal, many of whom have lived here for many years (ourselves included), and others who have moved in more recently, all chose to live in, or move to a rural environment because they value the peace, quiet, countryside views and access to peaceful countryside which they can enjoy for leisure activities. This proposal will take that away from them for ever.

For all the reasons outlined we would therefore urge the Council to reject this proposal and allow this part of north Bedfordshire to remain as a rural agricultural area.

Object

Representation ID: 7514

Received: 21/09/2021

Respondent: Wyboston Chawston & Colesden Parish Council

We write regarding a proposed major housing development under the name of ‘Dennybrook Garden Village’ and the devastating impact this would have on not just the immediate area, but also on the nearby town of St Neots.
We acknowledge the need for more housing and, where done responsibly, accept that this can benefit surrounding areas and business. We draw your attention to the developments nearby to this area, across the border, of Loves Farm and Wintringham, major housing builds constructed alongside the development of a major road improvement plan, with very little impact on local existing structures.
Dennybrook Garden Village on the other hand single handedly turns a small rural hamlet into a town the size of Kempston, with no apparent infrastructure plans relating back to Bedford Town, instead relying entirely on the nearby town of St Neots to accommodate its residents in terms of Traffic management, Surgeries, Policing etc. Furthermore, assuming a development close to a neighbouring Borough will create income without the expenditure would be naive as the neighbouring Council will demand a ratio of the tax income and/or possibly refuse to supply services, in particular medical.
From an environmental stance there are also inherent problems, last year the river Ouse flooded from Great Barford to St Neots Town centre, compounded by run-off from the proposed area. With the introduction of hardstanding and housing this occurrence will increase. The area is also Greenfield land, against all Government recommendations for new building. There are many Brownfield sites within the Bedfordshire boundary ready to accommodate housing without the massive impact. Furthermore, many smaller developments would have a negligible effect on infrastructure and environment.

Object

Representation ID: 7521

Received: 03/09/2021

Respondent: Mr Jonathan Hambleton

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Support

Representation ID: 7533

Received: 21/09/2021

Respondent: EF Wootton and Son

Agent: Phillips Planning Services

Our client strongly supports the proposed new settlement of Dennybrook Garden Village which is being promoted by Taylor Wimpey through the Call for Sites Process (977).

Our client has land at Top Farm, Wyboston (Sites 603 and 1354) which forms part of this proposal, and we can confirm that as part of a joint venture with other land owners, our client is committed to the release of this land to deliver the new settlement.

The purpose of this independent representation is both to support the inclusion of Dennybrook Garden Village, in the emerging Local Plan, and also to draw attention to the fact that if the new settlement options are not taken forward, our client’s land would remain available to address alternative strategies and can be released independently for a smaller scale of development in this location.

Our client has consistently promoted the land as being a location for the delivery of housing as part of development specific to the future needs of the Parish of Wyboston, Chawston and Colesdon, and as part of a new settlement. The proposal for the farm on its own is submitted under site 1354 (Land at Top Farm (Incorporating Chawston Lake & Morris Walk) and relates to the whole site, excluding the farm house and barns (approved for residential use some years ago and currently being completed).

The land at Top Farm is likely to be part of the first phase of the Dennybrook scheme, and therefore, if the Council do not support the new settlement at this stage and feel further work is necessary to support the Garden Village for inclusion in a future Local Plan, we would like to highlight that the Top Farm site could come forward at an early phase without prejudicing the delivery of the new settlement in the longer term. Indeed, some development here could be seen as an opportunity to “pump prime” the delivery of the proposed new settlement in this location, as the site is of sufficient size to accommodate 450 dwellings, a school, and other local services and facilities. This could form the nucleus of an early phase on which the bigger scheme could be built.

The second option submitted under Site 603 (Top Farm, Wyboston) is smaller scale, and promotes the idea of a small site for up to 20 dwellings to address local development needs, as well as being an attractive location for custom and self-build plots – please see our comments in respect of proposed policy SB1.

In terms of sustainability, there is a bus stop accessible by foot that connects the site to Biggleswade, Sandy, and St Neots. St Neots can be easily accessed from the site at a longer walking / short cycling distance, which provides a range of services, employment opportunities, and transport links. The site is therefore in a reasonably sustainable rural location. Development of this site will contribute towards the long-term vitality of the settlement and viability of these services.

In conclusion, our client’s preference is for the land to come forward as part of the Dennybrook Garden Village and as such would commend this proposal to the Council as a long term solution to growth in the Borough. If for whatever reason this is not preferred, the land will remain available to meet any alternatives that may suggest development in this area.

Object

Representation ID: 7557

Received: 21/09/2021

Respondent: C Smith

I am responding to the above consultation in which you outline four proposals for housing development.
Whilst it’s important to provide affordable housing in local areas, it’s also important to make sure that any plans follow consistent national and local planning principles, environmental policies and guidelines for appropriate supporting infrastructure – so that proposals are appropriate, climate and environmentally friendly and sustainable.
I have set out the key reasons for the objection to planning permission being granted for the Dennybrook (site 977) proposal and I propose that Twinwoods (site 883) or Colworth (site 1002) is clearly a better, more suitable and sustainable alternative.

1. Process and Disclosure: Concerns and Challenges
There are a number of concerns about the misleading disclosure of information – and the lack of time in which some residents have been given to consider quite material changes.
The Borough’s options paper in August 2020 showed the brown option as urban development on ‘brownfield’ sites with a large brown development over the whole of the local Staploe parish.
It’s unclear why the inaccurate and misleading local planning designation was included and presented and whether its due to a lack of understanding of the actual local planning designation but what is very clear is that there is ‘no’ brownfield land in our parish – as it is all clearly classed as ‘open countryside’.
This also calls into question whether the misrepresentation of the current planning designation for the proposed development renders the formal consultation invalid.
It’s also highly questionable why the local plan appears to be further misleading as it refers to 2,500 homes at Dennybrook up to 2040 when the developers’ vision for the site is for nearly 10,800 homes in the longer term.
Clarity on the reconciliation and timing of these two important levels of housing concentration as well as the likely impact on the local infrastructure and environment is material in properly considering and consulting upon the planning proposals.
In the Council’s draft Sustainability Appraisal (DSA) dated June 2021 it states that ‘all spatial options have been assessed’. This is incorrect and, again, misleading as options 2b, 2c and 2d clearly identify two new settlements – whose impact needs to be fully assessed and the findings included in the DSA. The options testing in the draft Sustainability Appraisal (DSA) are, as a consequence, inaccurate and incomplete and is contrary to the Environmental Assessment of Plans and Programmes Regulations 2004.
It is also noted that, residents of Honeydon were only informed about the expansion of the site, which is proposed to engulf 40% of Honeydon, some eight months after the deadline close for the call for sites – giving them just one month to consider this before the draft consultation.
Finally, it is important that throughout the whole process, conflicts of interest are identified and properly managed – and minuted as an accurate record of how they were approached.

2. Concentration and Impact on Inadequate Infrastructure:
The Borough is building houses at more than 3 times the national rate. Whilst its admirable that our borough is providing affordable housing to those in need, its totally inappropriate to provide concentration risks of housing developments without totally adequate infrastructure to support it on a sustainable basis.
Residents of the proposed Dennybrook development would be required to use personal transport to access shops, services and key transport links as they would be at least a number of miles from their nearest railway station.
Furthermore, due to the location of the proposed development, St Neots would naturally be the town centre relied upon by this new community, not Bedford as assumed, where St Neots is already unable to fully and properly support its local residents.
With a decline in the high street in both St Neots and Bedford, but particularly in St Neots, will there be sufficient jobs to meet the needs of new local residents? Has the employment plan been considered alongside the development plan?
At a time when the global and national community is pursuing a strategy of climate change transformation to target net zero emissions by no later than 2050, these proposals fly in the face of that global effort particularly since the proposal is to use ‘open countryside’ for development rather than urban development on brownfield sites in the Borough’s options paper in August 2020.
The proposal for Dennybrook will not just oppose national policy by using ‘open countryside’ and all the environmental disadvantages that clearly presents, it is also likely to ‘increase’ net emissions in this local area – providing a much less healthy environment and contributing to not mitigating global warming.
5. Key Objections to the Development of Dennybrook
The proposed development for Dennybrook is the least appropriate and has been inappropriately considered as a ‘brownfield site’ when in fact it is designated ‘open countryside’.
The key reasons why alternative sites are significantly and indisputably more appropriate than Dennybrook are:
• Destruction of greenfield: It is a purely greenfield site on grade 2 (good quality) agricultural land – therefore contrary to government policy
• In the future, greenfield sites will be incredibly important for sustainable environmental, food production and climate change reasons
• Town Centre Dependence and Concentration: The proposed development at Dennybrook will depend on St Neots and not Bedford – with a high number of unintended negative consequences
• Urban Sprawl: There will be insufficient segregation between St Neots and the new development – creating a material risk of ‘urban sprawl’ and consequences from ineffective planning policy
• Pollution: The proposed development at Dennybrook, for the reasons explained, will increase pollution of air, water, soil, noise and light.
• Climate Change Increased Risk: The choice of the use of ‘open countryside’ rather than an urban development or other preferences of Government Policy, will naturally increase net emissions and be contrary to the global aim of being net zero by 2050
• Flooding Risk: There are 5 water courses which feed into the River Ouse just upstream of St Neots from the Dennybrook area. There is a recognised track record of flooding which makes this an inappropriate place for high density housing which could lead to high insurance premiums to local residents or, as climate change evolves, a risk of residents bearing an uninsured risk – where the consequences on financial and mental unwellness of residents has been clear to see in other parts of the UK
• Over Concentration on Local Infrastructure: Many of the roads in the Dennybrook area are single track with high banks and sharp bends which are unsuitable for large volumes of traffic or for HGVs
• There are no mains sewers or gas, a telephone exchange that is some distance away and there is already pressure on the mains water pipe that leaks frequently in Bushmead Road
• Public Transport: The traffic in and out of St Neots is already heavy at key times of the day and there are no seats on trains from St Neots to London before any increase in the local population, a lack of additional parking. No buses at present and no safe routes to reach the station on foot or bicycle
• Public Services: An increased local population would naturally increase pressure on doctors and dentists
• Devastation of nature reserves: Over decades, nature reserves have developed naturally. Many roadside and highly valued wildlife habitats along these roads would be destroyed if these single track roads were to be widened
• Honeydon has, by far, the largest area of roadside nature reserves in the Borough – which would be destroyed
• A wide range of wildlife and biodiversity will be destroyed through this proposed development which includes protected species of Bath Aspargus, Small Eggar Moths, Sulphur Clover, Crested Cow Wheat, Red Kites, Corn Buntings as well as badgers, bee orchids, owls, egrets, skylarks and dragon flies.
• The setting of Listed Buildings and Areas of Importance: These include St Deny’s Church, Colmworth; Chestnuts and Dairy Farm Cottage in Honeydon; Tythe Farm; Manor Farm which has strong connections to the Church of Jesus Christ, Latter Day Saints and the Old Chapel in Chapel Close.
Summary
This letter sets out very clear and specific objections to the proposal to create a new area of development that would be known as Dennybrook (site 977).
Of the options that have been presented in the consultation, Bedford Borough Council’s own sustainability appraisals demonstrated and concluded that the alternative Option 2a is the preferred and most suitable option because urban development is more sustainable than rural.
Little Barford (site 907 – option 2b)y, ‘excluding’ Wyboston / Dennybrook, is the next most appropriate, which would provide additional 3,085 dwellings in the rail corridor and would create:
• A development in and around the urban area plus A421 transport corridor with rail based growth parishes
• Access to a large number of services and facilities including existing employment which would reduce the need to travel by car
Twinwoods at Thurleigh (site 977) is the next best alternative and more appropriate because:
• Urban Area is widely preferred, even expressed through government policy, to rural areas particularly ‘open countryside’ – and a significant part of Twinwoods is brownfield land
• Government planning policy requires brownfield sites to be prioritised over greenfield sites
• This choice is better aligned to the infrastructure, environmental and structural challenges that need to be properly addressed as part of a robust planning process
A further alternative would be Colworth (site 1002) for the reasons set out above.

Object

Representation ID: 7572

Received: 21/09/2021

Respondent: Mrs Barbara Morris

Wyboston/Dennybrook Proposals.

Support all Parish Councils reasons submitted and primarily Colmworth PCs.

Any housing approved would not result in any improved economic impact to Bedford as the most convenient town is St Neots which sits in HSC. The additional housing will be services by the facilities in St Neots as they have a comprehensive infrastructure in place. It will support housing need in HDC more than it ever would in Bedford BC area.

Scale of the project in respect of size and time would have a massive long detrimental impact on the area causing traffic congestion, noise and general disturbance to existing residents.

Area is very rural, few access roads and minimal infrastructure. Roads are not able to sustain volumes of traffic numbers. Many are unclassified and single track with safety issues. Visibility is extremely poor in many places. Farm machinery use is high as are movements by horses, cyclists, walkers.

No gas utilities exist in many of the villages.

Development is too large and destructive to wildlife habitats and rural country life.

Many better solutions exist, call for sites returned over 70,000 plots which could address housing need.

Object

Representation ID: 7579

Received: 21/09/2021

Respondent: Mr Stephen Evans

a)The proposal for ‘Dennybrook Garden Village’ is hugely excessive. This is no ‘Garden Village; it is a NEW TOWN and should be referred to as such.
b) The vehicular access to the A1 and A421 is already congested and dangerous when pulling out. The proposal could add another 10-20,000 cars.
c) The Government is prioritising brownfield sites. This proposal obliterates 2400 acres of prime agricultural land, along with the wildlife who live there.
d) The new population will not shop in Bedford, but go to St Neots, which is nearer and a more pleasant experience.
e) Our narrow lanes are already blighted by heavy goods vehicles, another 20-30 years of construction traffic will be an unacceptable burden of small communities.
f) This proposal seems to be contemporary with the building of the new railway AND the building of the new 3 tier Black Cat Roundabout flyover, hence a triple blow to Chawston and Wyboston. Building materials are currently in short supply.

Object

Representation ID: 7580

Received: 01/09/2021

Respondent: Miss Nicola Tagg

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S.
n addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of n addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of n addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Representation ID: 7748

Received: 22/09/2021

Respondent: Colmworth Parish Council

I do not support the proposal for a new “garden village” settlement at Dennybrook (site ID 977) included in three of the four options within the draft Local Plan 2040
(LP40).
I believe the Dennybrook proposal should be rejected for a number of reasons:
- Dennybrook delivers very few houses in the all important 0-5 year period, it is
the worst choice among the major sites.
- Dennybrook’s claims of housing delivery beyond year 5 at a rate of 500 per annum (10 sales per week, every week, for 20 years) seem highly optimistic,
way beyond the expectations of the other major developments. This creates a far higher risk of under-delivery than with other proposals. Even though BBC
is not relying on this delivery rate it highlights an unacceptable concentration of power in the hands of a single developer.
- The submission shows that the developer expects construction traffic on the site for over 25 years, that is an unacceptable burden on neighbouring communities.
- Dennybrook has comparatively poor access to Bedford, many people will favour St Neots which adds further economic damage to Bedford town centre which is in serious decline.
- Apart from the far end of the Dennybrook site near St Neots, the only exits from the site are unclassified roads incapable of handling the traffic volume.
The central road is a single-track road. Wilden Road is one of several local roads classified as “Unsuitable for HGVs” presenting a clear risk of unsuitable
traffic using local access privileges elevating accident risk. Neither the Dennybrook submission nor the Transport Model include any proposals for road widening or enhancement of the local minor roads that will be
overwhelmed.
- There is no shortage of high quality development opportunities for inclusion in the plan. The call-for-sites returned over 430 responses totalling in excess of
70,000 plots against a need of around 12,500 plots for completion of the plan.
There is no need to consider something as large and destructive as the Dennybrook proposal.
I recognise that the principal advantage of including a garden village settlement is that it creates the potential for a community of a size that can be largely self sufficient
and thus less reliant on neighbouring communities for services and facilities over time.
When the (originally much smaller) Wyboston site was assessed as part of LP35 BBC concluded that “the site is on the edge of the Bedford housing market area and
therefore the Council consider that if the garden village were to be allocated, it would contribute to meeting Bedford’s economy and housing need. However, the site lies very close to St Neots and it is likely that pressure would be placed on services and facilities in St Neots. This impact has not been assessed by the site promoter.” I believe this under-estimates the relative convenience and attractiveness of St Neots and thus overstates the likely contribution to Bedford’s economy and housing needs.
The site lies in the northeast corner of Bedford Borough and is significantly closer to the town of St Neots. It is likely that most new residents, in common with existing
residents in the area, will focus on that community for shopping and entertainment needs and to some degree employment. This presents a problem for BBC as the
site will be relatively unattractive to residents whose lives currently focus on Bedford, many purchasers are likely to be drawn from the St Neots area and thus the site may
not adequately address anticipated growth in housing demand from Bedford.
Moreover, Bedford will receive comparatively little economic benefit from the site’s residents and it is even possible that Bedford may see a negative impact from some of its wealthier residents who currently commute to London from the Midland station who choose to relocate to this site to benefit from the proposed Little Barford rail
station. Thus the site will likely fail to support Bedford housing needs and fail to provide economic growth to Bedford in proportion to the scale of the development.
In terms of delivery of the site the program is heavily dependent on road access arising from the planned improvement works around the Black Cat roundabout A421/A1 junction, the timetable for which remains unassured and the necessary capacity improvements are not guaranteed. The DCO has not yet been granted and a delay to the completion of the Highways England’s scheme could have a significant impact
on both the delivery of housing and local traffic flow generally. No work has been done within the Dennybrook proposal to evaluate the mitigation that would be
required to the Black Cat Roundabout should the Highways England scheme not progress or be delayed.
The Dennybrook site lies in a very rural situation where there are exceptionally few existing facilities in the immediate vicinity. There is minimal employment, little public transport, no retail outlets and no educational resources locally at present. The proposal allocates some land towards the provision of such facilities but the
scheduled build-out rate for the site is unlikely to provide self-sufficiency in these facilities for more than a decade leading to significant reliance on neighbouring
communities, particularly in the St Neots area, placing a substantial burden on those communities. Once the development is complete there will be inadequate gaps
remaining between the development and the communities of Colmworth, Wyboston and others to prevent coalescence with the existing settlements, effectively erasing the identity of historic settlements dating back to medieval and earlier periods.
The location of the site means that, for employment purposes in particular, many residents will be commuting above-average distances and will be almost wholly
reliant on private cars. The distances for most would not encourage walking and cycling and while there is a new railway station planned for the area, possibly around
Little Barford, this will best suit London commuters for the most part. Residents working in and around Bedford Borough are unlikely to find it either efficient or
economic to travel away from Bedford to the new station in order to take a train back to Bedford Midland station for a connecting train, bus or taxi onto their employment
destination.
In the LP35 assessment of the site BBC concluded that “the existing walking and cycling provision near the site is generally good, however some of the surrounding
infrastructure requires improvement (e.g. subway under Northfield road, footbridge over the A1).” However, the proposed is site is three miles in length and two miles
from the midpoint to Eaton Socon. Accordingly it seems unlikely that walking will be feasible outside the site boundaries. BBC noted “The site is located in a relatively
convenient location for vehicle journeys on the strategic road network, which may be a deterrent to non-motorised travel.“
There is no doubt that residents would be almost wholly dependent upon the private car, that is simply an established characteristic of rural life and nothing in this
proposal contributes to an effective solution to this issue. As a result, the proposal cannot be considered to be the most environmentally sound or sustainable solution
to Bedford’s housing needs. While the site will be inconvenient and unattractive to many in Bedford, there is likely to be increasing demand from residents working in the Cambridge area, looking to benefit from the new East West Rail service when available. However, these housing needs could in all likelihood be accommodated within a much smaller development such as site ID 907 at Little Barford, very close to the proposed East West Rail
station. It is difficult to see how the Dennybrook development in its current form could deliver the most appropriate strategy for expanding Bedford.
Within the analysis for LP35 the Council’s view was that the timing was not right to take forward a garden village in Wyboston. The Council wanted to have more
certainty on the timing of delivery of the Black Cat scheme, the A428/Caxton Gibbet scheme and the possibility of the A1 realignment. In particular, the Black Cat and A428 projects were considered crucial pre-requisites to a major Wyboston development and while plans and surveying for these road schemes have moved
forward, there is still no certainty as to the timing of completion. On present scheduling, construction traffic for Dennybrook would be heaviest at a time when the
Black Cat, the A1, the A421 and the A428 are all subject to partial and temporary closures adding to the current congestion.
There are multiple points of access to the Dennybrook site but currently there is no direct access to classified roads. The primary access point will be at the eastern end of the site via the A4280 onto the A1 and A421 at the Black Cat junction. There are no other A or B class roads near the site. The main access point on the western side
is Mill Road, a single-track road that runs through the site. Thus road access, particularly in the direction of Bedford, can only be described as inadequate for such
a large development.
When the site was assessed as part of the LP35 analysis, the Council stated that “the existing road widths, visibility and constraints are inappropriate to accommodate the proposed levels of development” “Access to the A1 via rural roads is currently
considered to be inadequate and unacceptable, with no proposals for improvement identified.” That conclusion related to a site of only 4,000 homes compared to the
current proposal for 10,150 homes. Despite being aware of the problem for several years now the promoters have not been able to incorporate any suggested solution
within the proposal.
The commercial value of the Dennybrook project would exceed £3 billion. Despite this, the site promoters have provided extremely little information about, or
commitment to, infrastructure improvements that would need to be delivered. There is no material information showing new roads, road widening schemes, road junction redesign, footpaths and cycle paths, public transport support, public services, leisure
facilities etc. The promoters are seeking permission to build a new town the size of
Biggleswade but are focused almost solely on the sale of houses and have given no commitment to providing the key components that comprise a successful and
desirable town environment. While there is a long way to go before the site has formal planning permission, the inclusion of the site within the LP40 would give
effective commitment to the project, essentially a commercial decision would have been made without most of the crucial facts, specification and evidence that a project of this magnitude would ordinarily provide as a prerequisite. That process introduces an unacceptable degree of project risk that is so easily avoidable. This proposal places too much control in the hands of the site promoter at the expense of BBC.
A key concern is that this single site would be selected to address almost half of all housing need in Bedford Borough for an entire generation. It seems extremely
unlikely that this scale of development in what is probably the most rural part of the Borough, largely detached from Bedford by distance and transport accessibility, can
be achieved at the rate suggested by the promoter of 500 units annually for two decades. There is a material risk that development will be moderated to support
prices meaning the site will not deliver housing at the rate promised affecting this and future Local Plans. That would also lead to a connected concern about
extension of the development schedule from the current 25 years to much longer meaning that local communities may be affected by construction traffic for 30 years
or more. That seems wholly unreasonable when there are so many other site alternatives that will not have such a destructive effect on existing residents’ lives.
Although not directly relevant to a decision on housing allocation it is worth noting that BBC made a very strong presentation to attract the East West Rail link into
Bedford town centre because of a marginal economic gain. It makes no strategic sense therefore to promote a housing scheme that is the most economically
disadvantageous to the Borough of all the proposals arising from the call-for-sites.

Object

Representation ID: 7771

Received: 22/09/2021

Respondent: Mrs Ann Spencer

I strongly object to the Dennybrook plan.
I think the Dennybrook plan would bring chaos to our local roads and our rural way of life.
Several roads surrounding and leading to the site are single track roads. None of these have been scheduled for widening.
The size of the Dennybrook plan would be a disaster when considering the very basic facilities we have – how long would it take for new schools, doctor’s surgeries, updating of sewerage systems etc.
I am sure Dennybrook would be beneficial to St Neots and Huntingdon Council and I am sure other sites such as Twinwoods would help Bedford prosper again.

Object

Representation ID: 7776

Received: 22/09/2021

Respondent: Mr Jeremy Freedman

I am registering my objection to the proposal known as “Dennybrook” for the land to the West of Wyboston.
I object on environmental grounds to the ripping up of thousands of acres of fields to provide housing when there are so many brownfield and redundant urban sites available.
We live in an environment of rapid climate change. The impact of this development will be catastrophic.
We are witness to species extinction. Again, the impact will be catastrophic.
We face serious food supply problems. These arable fields will be needed for food security. We face major supply problems in the construction industry. We should be recycling existing buildings not creating new ones out of scares resources.
I also object on location grounds. We do not have the infrastructure in NE Bedfordshire to support this development. Where are the roads? The schools? The medical services? The shops? And for the thousands of people that are destined to live in this new development, where are the jobs? Clearly there are none locally, and transport links will be needed. The nearest station is miles away on the other side of St Neots.
I am sorry to say that this is a poorly hatched and badly thought out scheme which has no regard to the problems we face locally, nationally and internationally in the 21st Century. I am the first to recognise that we need to increase the housing stock as populations increase and demography changes. This is not the way to do it.

Object

Representation ID: 7777

Received: 22/09/2021

Respondent: Mr John Hughes

May I strongly object to the proposed Dennybrook site, which will take acres of top quality agricultural land, which is more needed now than ever before due to us leaving the EU and having to grow more of our own food and a growing population to feed.
Also being so close A1, anybody who uses it at night and morning will tell you that it gets congested every day and is a non-starter from day one. The smaller B roads are inadequate now with commuters and farm traffic slowing everything down.
As a resident of Colmworth since 1939 and living through WW2, this proposal is outrageous in the extreme and a small town is the last thing that is needed on this valuable farm land with every household now having multiple cars and no talk of minor road improvement.
This is not a brownfield site and should not be seen as one when there are these Government approved brownfield sites available

Object

Representation ID: 7893

Received: 23/09/2021

Respondent: Miss Tracey Measures

Denny Brook (and railway line)
Firstly, why is Grade A agricultural land even being considered for building??!We are not making any more farmland, when it’s gone, it’s gone! How will we feed this country when we’ve built on the last of our decent farmland?
There are plenty of vacant homes/businesses/shops in Bedford, that cabn be turned into suitable homes. Why would you buy a house 10 miles from Bedford, one mile from St Neots and then work/shop/set up businesses, anywhere but St Neots?! We lose again!
We are a beautiful, rural, agricultural community and do not need any massive development here. We are 7 miles from St Neots, 8 miles away from Bedford, which can only mean more cars on our shoddy pot-holed roads.
The proposal for 52 houses in the orchard opposite my Grade 2 listed cottage will mean @ 200 cars from this one site alone! Not to mention ground works literally shaking my house for the next?? years. Please keep to Bedford suburbs, try and do your best for Bedford and Bedfordshire, not the easiest option!
Do not build on farmland. We do not want to be dependent on the world to feed us – we are not making any more agricultural land!

Object

Representation ID: 7910

Received: 24/09/2021

Respondent: Ms Sharon Wootton

I would like to object to this rediculas proposal for one main reason. This number of homes could creat up to 2000+ young people of all ages. The only town able to cope with there leisure and sports needs etc is Bedford. A school and a community centre is totally insufficient. This site is so far away from Bedford, the young people will have nothing to do other then get into trouble. A site next to Bedford with easy access must be much more sensible. Travel routes to Bedford are not able to cope with current traffic needs with rat runs through our villages and excess speeds ( no police action ever to prevent it).This will only get much much worse. This site is probably the worse option available. The land owners are the only poeple in favour I would think!

Object

Representation ID: 7974

Received: 24/09/2021

Respondent: Ms Lorraine Jewell

Again this section is mainly populated with advice sought from 3rd parties (and a planning advisor whose professional services were paid for by a fund I donated to and allows me to provide my views on technical information and to assist me in articulating my views. They fully represent my personal view and should not be discounted as they have been supported by friends, a planning advisor and the local Staploe Parish Council.


Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Representation ID: 7984

Received: 24/09/2021

Respondent: Mrs Nicola Gooch

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977

Land west of Wyboston (Dennybrook) is considered the least preferred option and should be discounted as a sustainable location for development by Bedford Borough Council. The following comments and observations relate to the Call for Sites submission by Taylor Wimpey for a ‘new settlement’.
Under form ID: 977, submissions have been made for a new settlement covering around 725 Hectares of land, and providing between 7,500 – 10,150 dwellings (35 dph). BBC have identified the site as a potential ‘new settlement’ though providing around 2,500 new homes.
The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single track roads (many of which are designated as unsuitable for HGVs) and no settlement policy area. It is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that adequately address the impacts, and in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004.
Housing need has been identified through the Council’s LHN. Using the process set out in the Planning Practice Guidance “Housing and economic needs assessment” (MHCLG – updated December 2020) the minimum annual LHN figure is 1,305 dwellings per annum. This equates to 26,100 dwellings across the period 2020 – 2040. However, existing committed sites and windfall provide a figure of 13,000 new homes. This provides a figure of 13,100 additional dwellings over the plan period. It is noted that Bedford Borough Council need to deliver 12,500 homes as a minimum. Regardless which of the figures proposed, the strategy of option 2b (including 2,500 homes at Little Barford) meets the Council’s housing requirement and negates the need for Dennybrook as a new settlement.
When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots, with a possible merging into Wyboston and the hamlets of Honeydon and Begwary would be engulfed by the development. Given the scale of the proposed development at Dennybrook, even at 2,500 dwellings, there would a potential coalescence to the existing settlement of St Neots. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’. It should also be taken into consideration that St Neots is experiencing its own strategic growth with an eastern extension 3,265 dwelling and 20 Ha of employment land over the plan period. Therefore, a new settlement directly to the west of the existing settlement of 2,500 would significantly increase the size of St Neots and may affect delivery rates for housing due to competing sites.
The transport impacts are acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The proposal will not benefit from a choice of sustainable modes of transport as opposed to other developments, such as urban extensions and the proposed development at Little Barford. Little Barford offers a varied choice of sustainable modes of public transport, including the possible linkage to the East West rail station south of St Neots. It is anticipated that there will be limited employment associated with Dennybrook with commuting considered necessary to nearby employment areas, for example, south of St Neots, Bedford or Cambridge via train. This would be contrary to sustainability objectives identified by BBC, and contrary to paragraphs 73, 104, 105, 106, and 110 of the NPPF, not to mention existing policies within the adopted Local Plan, namely Policies 2S, 87, 88, and 90S. In addition, the Dennybrook site does not align with a strategic transport corridor growth strategy, including rail.
In highways terms, it has been identified previously that Parish of Staploe is rural in character, with most of the road network narrow and single track. The inclusion of 2,500 dwellings (or over 10,000 according to the site promoted) would require significant infrastructure interventions, including the substantial widening of existing roads and junctions, which would lead to an urbanised appearance it what is a tranquil and idyllic countryside setting. Bedford Borough Council confirm within their assessment of the site submissions, that junction or highway capacity issues are a ‘serious capacity constraint’.
These representations are supported by a Highways Technical Note (Appendix 1) which has reviewed the Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040. The Technical Note considers that the Transport Modelling is fundamentally flawed. In summary, no validation or calibration of the traffic model has been undertaken, leading to significant discrepancies. Furthermore, within the Transport Model documents, it is quoted that average departing trips are 20 to 25 vehicles. When looking at the development scenario with the transport model of 2,500 – 10,150 dwellings, and using a departure rate of 0.25 departure trip rate, this results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicles used by the AECOM model, assuming they have loaded it per node. AECOM may argue that the reduction is due to sustainable modes of transport being used. However, it is made clear within paragraph 4.6 that the site offers very little in terms of alternative sustainable means of transport. Accordingly, the Transport Modelling by AECOM cannot be wholly relied upon.
The landscape setting for the Parish of Staploe is one of a rural character, containing small hamlets, interspersed agricultural buildings, small holdings and arable agricultural land. As mentioned above, the roads are narrow and winding, and contribute to the rural setting. This form of land extends from the A1 to the east to Church End, Colmworth to the east, down to Colesden to the south, and up to the Bushmead Road to the north. The landscape character is depicted within the Council’s Landscape Character Assessment (LCA), updated October 2020. The wider Parish of Staploe falls within the Thurleigh Clay Farmland character area (1D). Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss their distinctive character/ ‘Ends’; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 new dwellings would significantly and permanently erode the rural character of the Parish, contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
The Dennybrook area includes a number of roadside nature reserves which contain the rare Bath Asparagus, sulphur clover and crested cow wheat. In addition, the hedgerows are a haven for birds and wildlife such as the rare Small Eggar Moth. The fields are valued breeding sites for corn buntings, skylarks and partridge and there are a very high number of apex predators such as badgers, foxes, red kites etc. which suggest that wildlife is thriving.
There are also several Grade II Listed Buildings located within the Parish of Staploe, and would be affected by the proposed development at Dennybrook. It is evident that the Council’s assessment to Call for Site states ‘The proposal has the potential to cause harm to heritage assets. This harm may range from low to high. There may be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons, further assessment will be undertaken to more fully explore impacts on significance and options for harm reduction and mitigation. This further assessment may ultimately lead to the conclusion that the site should not be allocated.’ It is assumed by the above comments that further assessments are required before the site can be considered further as an allocation. It is clear that the existing Listed Buildings are dispersed throughout the area of the proposed development, causing potential impacts to their setting.
A further point to consider is that most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
In addition to the above, the Sustainability Appraisal scoring for the proposed new settlement of Dennybrook identifies it as scoring lower than Spatial Option 3a. this spatial option was effectively discounted at the ‘Issues and Options’ consultation stage.
Staploe Parish Council believe that such a large development would increase the flood risk in St Neots because there are several brooks which feed into the rivers just upstream of St Neots. St Neots has experienced significant flooding – most recently in August 2020 and December 2020. The brook in Honeydon and Colmworth Brook both flooded at these times. Building on this large area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
The residents of Honeydon and Begwary would be engulfed by this development. These small hamlets would entirely lose their identities. Residents chose to live in these locations for their peace and quiet and rural character. Many keep livestock and are concerned that this may no longer be possible adjacent to a new town. Valued local views would be lost – across towards Colmworth and the church but also between Begwary and Tithe Farm and many other valued open rural views.
Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road. The Bushmead Road is not suitable for the existing level of traffic.
Overall, the land west of Wyboston (Dennybrook) does not offer a truly sustainable form of development, and thereby contrary to policies contained within the NPPF and of the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

100 Word Summary Dennybrook Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Representation ID: 8031

Received: 28/08/2021

Respondent: Mrs Lorraine Knight

The NPPF under section 11 requires for making effective use of land and that planning authorities should take a proactive role in identifying and bring forward land, including brownfield sites. I question why the BBC haven't put forward Twinwoods within the Local Plan 2040 which has an area of brownfield within its proposal, BBC argue about the pressure on the A6, however, selecting Dennybrook to the East of the borough also has its challenges regarding transportation links, along with other quantifiable reasons for it not to be selected. Listed below are reasons why Dennybrook is an unsustainalbe location and why this site should be removed from the Local Plan 2040 proposal:
- The location of Dennybrook will flood the market with a dedicated location, this will impact the BBC by not delivering on the housing numbers required to meet targets - there is also a failure within the lcoal plan to outline a realistic delivery of housing across the borough, currently it's based on assumption.
- Dennybrook is isolated - as the crow flies it's approx. 7 miles from Bedford Town Centre, 6 miles from Sandy and 3 miles from St Neots, this will lead to people movement having to be via cars, buses etc. putting additional burden on the current road infrastructure, there are no plans laid out to deal with traffic wanting to go to Bedford via non-A or B listed roads, let alone putting in a new road to support this additional traffic and keep it out of existing villages and off unsuitable small country roads.
- Dennybrook is in a remote location to support the proposed site - there is already pressure on existing local services e.g Doctors, Hospitals and Fire Services who are already stretched, concerns arise on what would happen in an emergency and which council will be asked to support this isolated site, Huntingdonshire, Cambridgeshire, Bedfordshire? It's clearly a concern that this site is so far east that no one will want to wait for an ambulance to attend a heart attack patient which has to come along narrow village roads or via the A421, which on most days is lined with vehicles waiting/queuing to enter the Black Cat Roundabout.
- Dennybrook location to the proposed EWR new station - if we look at the proposed position of the site you have to on all occasions cross the A1 to get to either of the new proposed stations be it St Neots South or Tempsford, none can be accessed on foot and would require propelled vehicle transportation. We know that the distance is approx 5 miles away from both new proposed stations and too far for the average person on bike on a regular bases, let along having to cross the A1 corridor. The proposal from the site promoter is only theoretical and no evidence is forthcoming on how this will be delivered, they remark that they intend to work with the EWR consortium.
- Dennybrook gas pipeline and mineral deposits - the national gas pipelines runs through the site and although it's planned to grass over and provide green space over the pipeline it appears again no risk assessment is provided to explain how this is a safe option for people living right next to the gas pipeline. Mineral deposits are also present on this site and surrounding areas, what is the plan to extract the minerals, this again is missing from the proposal.
- Dennybrook waste water - within the proposal there are no details to support waste water infrastructure, remembering this is an isolated site and will add pressure on neighbouring councils e.g. St Neots or Tempsford wastewater treatment facilities.
- Dennybrook Heritage - on the western side of the development lies significant heritage buildings, a Grade 1 listed church of St Denys, Colmworth and located next to the church is a Grade 2 listed Manor house along with four Grade 2 converted farm buildings, due to historical importance residences are governed by restrictive covenants. There has been a failure to properly assess the significance of this area within the proposal, especially St Denys church, there are regulations set out within the NPPF and these need to be followed.
- Dennybrook agricultural land - if you look at the other call for sites proposals there is a question about why Dennybrook was selected if you look at the fact this land rates Grade 2 and some Grade 1 agricultural land, the best and most versatile land. This goes against the government policy and their plans for the environment. There are other sites like Twinwoods who have a significant amount of Grade 4 land along with Grade 2 and a small amount of Grade 3.

To conclude, the Local Plan lacks clarity, local engagement and support, we understand the need and reason for this plan and the national policy for the Oxford to Cambridge Arc however, the fact Dennybrook has been included without clear deliverables and based on assumptions is unacceptable. The environment impact will be great and to develop Grade 1 & 2 agricultural land where other sites are available via call for sites is not justifiable

Object

Representation ID: 8032

Received: 24/09/2021

Respondent: Mrs Kate Abrahams

I am responding to the above consultation, in which four proposals for housing development are outlined. I am outlining my key reasons for objecting to the Dennybrook Garden Village Site ID 977 and proposing that Little Barford (site ID 907), Twinwoods (site ID 883 ) or Colworth (site ID 1002) would be better, more suitable and sustainable alternatives.
1. Inappropriate and Inaccurate Disclosure
I have lived in Staploe Parish for over 30 years and most of the planning applications of which I have been aware have been rejected because Staploe is designated open countryside. Bedford Borough Council’s options paper in August 2020 for some, unexplained reason, designated most of Staploe parish as a brown option, rendering it appropriate for urban development. There are no brownfield sites in this parish and this misrepresentation should be explained and should render the formal consultation invalid. In the future, greenfield sites will be increasingly important for food production and to combat climate change and should be valued as such.

2. Destruction of Greenfield Site
Most of the land covered by the Parish of Staploe is Grade 2 agricultural land as identified by the Agricultural Land Classification. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: “recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…”. and that “where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality”.
Grade 2 agricultural land is considered to be the best and most versatile agricultural land so constructing Dennybrook would be contravening Government Planning Policy which requires that brownfield sites be selected as a much greater priority than greenfield sites.

3. Poor Local Road Infrastructure
The road infrastructure is totally inappropriate to sustain a significant increase in volume of traffic; the southerly exit from Dennybrook is ¾ mile from the A1/A421 junction and there is likely to be significant disruption in the next ten years with the A428 dualling and alterations to the Black Cat roundabout layout. The northern exit would be on to the Bushmead Road. This is already a dangerous road, which is prone to flooding and enters a residential area in St Neots with a school and traffic-calming measures. Anyone living nearby knows that traffic congestion is significant, particularly at rush-hour and at the start and end of the school day.
Most of the roads inside the parish and going towards Bedford and villages to the west are single track, many with high verges and poor visibility. Many of them are designated as unsuitable for heavy goods vehicles. Verges have been nurtured as nature reserves over the years and are highly valued wildlife habitats. Bath asparagus, small eggar moths, sulphur clover, crested cow wheat and orchids grow along the verges and red kites, corn buntings, badgers, owls, egrets, skylarks and dragon flies are frequently seen in the lanes. The peace and tranquillity of the roads is appreciated by walkers, horse-riders and cyclists.
The transport model used by AECOM has significantly under-valued the number of vehicle trips and Dennybrook is too far from the proposed new East/West railway station or St Neots station to avoid a significant increase in car-use.

4. Town Centre Appropriation
Those of us living in the parish know that we are between 8 and 13 miles from Bedford and “out of sight, out of mind”. Dennybrook residents would look to St Neots and not Bedford for shopping and business-access, negating any valued of the development to Bedford and Bedford town centre and putting significant strain on already overstretched resources in St Neots.

5. Flooding
There are several water courses which feed into the River Ouse just upstream of St Neots from the Dennybrook area. There is regular flooding in several sites in the parish when we have heavy rainfall and St Neots had significant flooding in August and December 2020. The risk of flooding will be compounded with housing development, and an increase in surface-water drainage would further increase this flood-risk in both St Neots and Honeydon.

6. Listed Buildings and Areas of Importance
Buildings which would be affected by this development include Grade 1 listed St Denys Church Colmworth, Grade 2 listed Chestnuts and Dairy farm Cottage, Honeydon, Tythe Farm, Manor Farm and the Old Chapel.

Object

Representation ID: 8050

Received: 02/09/2021

Respondent: Mrs Deidre Higgins

Why are you considering a new town at Honeydon ( Dennybrook- what a silly name) . It is not brownfield but is agricultural land. The road structure is completely unsuitable so new roads will have to be built. Please put the housing at Twinwoods which has the A6.

I always knew that Bedford Borough would not protect the countryside. This and EWR plans have proved it. The Mayor and the council have certainly lost my vote in the future.

Object

Representation ID: 8082

Received: 25/09/2021

Respondent: Miss Deborah Colgrave

My family and I oppose the Dennybrook proposed development.

1. The land is high quality agricultural, growing essential crops. Not brownfield site. Twinwoods would be much more suitable for such a large development and includes brownfield elements and much better road structure.
2. The site is in a very rural area with few access roads, incapable of handling the volume of traffic. Several are track roads. It would be absolute chaos and also encourage more car use.
3. Construction traffic would create huge disruption for decades to come.
4. The proposal is such a huge development that it would totally wipe out this rural area and its historic settlements.
5. I fail to see how this site would benefit Bedford. People would be more attracted to St. Neots area for shopping and employment.
6. The call-for-sites by BBC received hundreds of responses, so there is no need to consider something as large and destructive as Dennybrook would be.
7. The lovely views we have would be spoilt and gone forever.

Object

Representation ID: 8085

Received: 25/09/2021

Respondent: Mr and Mrs John and Di Hey

Dear Sir/Madam
Consultation Response: Dennybrook – Local Plan 2040
I am responding to the above consultation in which you outline four proposals for housing development.
Whilst it is important to provide affordable housing in local areas, it’s also important to make sure any plans follow consistent national and local planning principles, environmental policies and guidelines for appropriate supporting infrastructure – so that proposals are appropriate, climate and environmentally friendly and sustainable.

We have set out the key reasons for the objection to planning permission being granted for the Dennybrook proposal and we propose and alternative that is clearly a better, more suitable and sustainable alternative,.

1. Process and Disclosure: Concerns and Challenges.
The Borough’s options paper in August 2020 shows the brown option as urban development on ‘brownfield’ sites with a large brown development over the whole of Staploe parish.
It’s unclear why the inaccurate and misleading local planning designation was included and presented and whether its due to a lack of understanding of the actual local planning designation but what is very clear is that there is ‘no’ brownfield land in our parish – as it is all clearly classed as ‘open countryside’.
This also calls into question whether the misrepresentation of the current planning designation for the proposed development could render the formal consultation invalid.
It’s also questionable why the local plan appears to refer to 2,500 homes at Dennybrook up to 2040 when the developers’ vision for the site is for nearly 11,000 homes in the longer term.
Clarity on the reconciliation and timing of these two important levels of housing concentration as well as the likely impact on the local infrastructure and environment is material in properly considering and consulting upon the planning proposals.
Finally, it’s noted that, residents of Honeydon were only informed about the expansion of the site, which is proposed to engulf 40% of Honeydon, some eight months after the deadline close for the call for sites.
2. Concentration and impact on Inadequate Infrastructure
The Borough is building houses at more than 3 times the national rate. Whilst it is admirable that our borough is providing affordable housing for those in need, it’s totally inappropriate to provide concentration risks of housing developments without totally inadequate infrastructure to support it on a sustainable basis.
Residents of the proposed Dennybrook development would be required to use personal transport to access shops, services and key transport links as they would be at least x miles away from their nearest railway station.
Furthermore, due to the location of the proposed development, St Neots would naturally be the town centre relied upon by this new community, not Bedford as assumed, where St Neots is already unable to fully and properly support its local residents.
With a decline in the High Street, in both St Neots and Bedford, but particularly in St Neots, will there be sufficient jobs to meet the needs of local residents? Has the employment plan been considered alongside the development plan?
At a time when the global and national community is pursuing a strategy of climate change transformation to target zero emissions by no later than 2050, these proposals fly in the face of that global effort particularly since the proposal is to use ‘open countryside’ for development rather than urban development on brownfield sites in the Borough’s options paper 2020.
The proposal for Dennybrook will not just oppose national policy by using ‘open countryside’ and all the environmental disadvantages that clearly presents, it is also likely to ‘increase’ net emissions in this local area – providing a much less healthy environment and contributing to, not mitigating global warming.
Option 2a: Proven More Suitable Alternative
Bedford Borough Council’s own sustainability appraisals demonstrated and concluded that the alternative Option 2a is the preferred and most suitable option because urban development is more sustainable than rural.
Importantly, development within urban areas performed best particularly in reducing carbon emissions, promoting town centres (which incidentally are in decline), encouraging physical activity, delivering residents’ needs, access to community services (which are so important to mental wellness) and reducing the need to travel and promoting sustainable types of travel. New stations South of Bedford are planned and the A421 has capacity for additional traffic.
3. Government Planning Policy – Application and Relevance to These Proposals.
Government planning policy requires that brownfield sites be selected as a much greater priority than greenfield sites for very robust reasons. One of these reasons they quote is that developments must recognise “the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land” and that “where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of higher quality”.
In further support of this, a relevant definition within the National Planning Policy Framework is:
“Best and most versatile agricultural land: Land in grades 1,2 and 3a of the Agricultural Land Classification”.
The land proposed for Dennybrook at Honeydon and Wyboston is mostly Grade 2.
There are alternative, much more suitable sites, which are brownfield land, at Twinwoods, and much of the East West Rail route (Bedford to Cambridge).
On these grounds alone, as a further alternative to Dennybrook or even an urban development, the brownfield site on Twinwoods is much more suitable, particularly as:
• It does not flood
• It has no major watercourses and is distinct from other settlements – so no loss of identity for existing settlements
• Government planning policy seeks to develop brownfield land ahead if greenfield land (open countryside)
4. Key Objections to the Development of Dennybrook
The proposed development for Dennybrook is the least appropriate and has been inappropriately considered as a ‘brownfield site’ when in fact it is designated ‘open countryside’.
The key reasons why alternative sites are significantly and indisputably more appropriate than Dennybrook are:
• Destruction of greenfield: It is a purely greenfield site on grade 2 (good quality) agricultural land – therefore contrary to Government policy.
• In the future, greenfield sites will be incredibly important for sustainable environmental, food production and climate change reasons.
• Town Centre Dependence and Concentration: The proposed development at Dennybrook will depend on St Neots and not Bedford – with a high number of unintended negative consequences.
• Urban Sprawl: There will be insufficient segregation between St Neots and the new development – creating a material risk of ‘urban sprawl’ and consequences from ineffective planning policy.
• Pollution: The proposed development at Dennybrook, for the reasons explained, will increase pollution of air, water, soil, noise and light.
• Climate Change Increased Risk: The choice of the use of ‘open countryside’ rather than an urban development or other preferences of Government Policy, will naturally increase net emissions and be contrary to the global aim of being net zero by 2050.
• Flooding Risk: There are 5 water courses which feed into the River Ouse just upstream of St Neots from the Dennybrook area. There is a recognised track record of flooding, which makes this an inappropriate place for high density housing, which could lead to high insurance premiums to local residents or, as climate change evolves, a risk of residents bearing an uninsured risk - where the consequences on financial and mental unwellness of residents has been clear to see in other parts of the UK.
• Over Concentration on Local Infrastructure: Many of the roads in the Dennybrook area are single track with high banks and sharp bends which are unsuitable for large volumes of traffic or for HGVs.
• There are no mains sewers of gas, a telephone exchange that is some distance away and there is already pressure on the mains water pipe that leaks frequently in Bushmead Raod.
• Public Transport: The traffic in and out of St Neots is already heavy at key times of the day and there are no seats on trains from St Neots to London before any increase in the population, a lack of additional parking. No buses at present and no safe routes to reach the station on foot or bicycle.
• Public Services: An increased local population would naturally increase pressure on doctors and dentists.
• Devastation of Nature Reserves: Over decades, nature reserves have developed naturally. Many roadside and highly valued wildlife habitats along these roads would be destroyed if these single track roads were to be widened.
• Honeydon has, by far, the largest area if roadside nature reserves in the Borough – which would be destroyed.
• A wide range of wildlife biodiversity will be destroyed through this proposed development which includes protected species of Bath Asparagus, Small Eggar Moths, Sulphur Clover, Crested Cow Wheat, Red Kites, Corn Buntings as well as Badgers, Bee Orchids, Owls, Egrets, Skylarks and Dragonflies.
• The Setting of Listed Buildings and Areas of Importance: These include St. Deny’s Church, Colmworth; Chestnuts and Dairy Farm Cottage in Honeydon; Tythe Farm; Manor Farm which has strong connections to the Church of Jesus Christ, Latter Day Saints and the Old Chapel in Chapel Close.

5. Alternative and Better Suited Sites
As it is a brownfield site, Tempsford Airfield would be ideally suited for development and far better, along with Twinwoods, rather than obliterating the Hamlets of Duloe, Staploe, Honeydon and Wyboston.

Our challenge is also whether any thought has been given to how GP Surgeries, hospitals and schools are expected to cope with such a massive influx of people. We are chronically short of all medical staff as it is and this also applies to teachers. Even if new hospitals and schools are built where are the qualified staff to man then?
Finally we should aim to be more self-sufficient in food production. Importing food massively increases C02 emissions, building on grade 2 farming land is totally irresponsible given the need to drastically reduce emissions.

Summary.

We have set out the very clear reasons for and the specific objections to the proposed development which creates a new area known as Dennybrook.
Having considered all the choices put forward by the Planning Department we believe that Tempsford Airfield would be ideally suited for development and far better, along with Twinwoods, because:
• Urban area is widely preferred, even expressed through government policy, to rural areas particularly ‘open countryside
• Government planning policy requires brownfield sites to be prioritised over greenfield sites
• This choice is better aligned to the infrastructure, environmental and structural challenges that need to be properly addressed as part of a robust planning process.
We hope that this is helpful.

Yours Faithfully

John and Do Hey

Object

Representation ID: 8088

Received: 02/09/2021

Respondent: Huntingdonshire District Council

Huntingdonshire District Council object in principle to the potential new settlement at Wyboston
(known as Dennybrook Garden Village). The closest elements of the proposal immediately adjoin the
western side of the A1 either side of Bushmead Road and would be situated within 100 metres of
the western edge of St Neots which gives rise to significant concerns over the many impacts it would
be likely to have for local residents.
Huntingdonshire District Council is extremely concerned about the long term intended scale of the
proposed development at Wyboston (Dennybrook). It is noted that the developer, Taylor Wimpey,
submitted the site to Bedford Borough Council for 7,500 - 10,150 new homes. It is noted that the site
has however been included within three of Bedford’s preferred options for 2,500 new homes. This is
significantly less than the developer’s intentions for the site. The consultation material is unclear on
the justification for this reduction to 2,500 homes and the implications a reduced quantum of
development would have on the infrastructure and services capable of being provided.
Huntingdonshire District Council is very concerned about the feasibility of delivering just the reduced
scheme as it would be unable to provide sufficient infrastructure to meet all locally generated needs
and so would, in all probability, place extra demands on service provision within St Neots to the
detriment of their accessibility by local residents. It would be beneficial to gain clarity on Bedford
Borough Council’s long term ambitions for Dennybrook and whether the intention for the longer
term strategy beyond 2040 would be for continued expansion to a scale more aligned to the
developer’s stated intentions.
The Bedford Borough Transport Model: New Settlement West of Wyboston (April 2021) specifies
that it considered three development scenarios without and with proposed mitigation measures for
Wyboston (ranging for 2,500 to 5,150 new homes at Dennybrook by 2040 and up to the maximum
proposed settlement size of 10,150 dwellings by 2050). This reinforces the Council’s apprehension
over the long-term intentions for Dennybrook. This assessment leads to several detailed concerns,
namely:
• Paragraph 2.4.2, further explanation is required why ‘no employment has been assumed to
be associated with the proposed development for this assessment’. A development of this
potential scale in any of the scenarios should incorporate a mix of uses in order to support a
balanced and sustainable community. To assess the potential journeys and impact that
employment development may have on the transport network is essential to understand
comprehensively the mitigations required to make a scheme acceptable in highway terms.
• Figure 3.2 shows that without the proposed mitigation measures the traffic generated by
the proposed Dennybrook development is forecast to primarily use routes to the south of
the development towards Roxton and onto the A1 / A421 Junction, to the west towards the
north-east of Bedford town and the A6, and to the north to access St Neots via Bushmead
Road or Duloe Road. However, Figure 3.3 shows that the mitigation would increase traffic on
the northern roads Bushmead Road and Duloe Road in AM Peak hour (08:00 to 09:00) in the
2050 Dennybrook scenario, with paragraph 3.3.4 stating that the pattern of forecast
development traffic is not significantly altered by the proposed mitigation measures.
Implementation of Dennybrook will not be acceptable without adequate highway and nonmotorised
user infrastructure improvements to fully mitigate its impacts.
Figure 3.5 shows an increase in the forecast flow change from that forecast in the 2030 Local
Plan scenario to 2050 even with mitigation in the AM peak hour (08:00 to 09:00) along
Bushmead Road will worsen. This is unacceptable.
• Figure 3.11 shows the forecast volume-capacity ratio change from that forecast in the 2030
Local Plan scenario to 2050 including mitigation, AM peak hour (08:00 to 09:00). It shows
that there is a larger change on Duloe Road, Bushmead Road, Monarch Road and Nelson
Road within St Neots raising concern over the impact on residents along these routes.
• Table 3.6 shows an increase in delays to Bushmead Road / Staploe Road and Bushmead
Road / Duloe Road even with mitigation. Table 3.7 again shows significant impacts in terms
of increased delays which would be unacceptable, as such further mitigation measures
should be explored. If adequate mitigation cannot be incorporated within the scheme then
it would indicate the scheme cannot be successfully delivered.
Should the development strategy at the next stage of the Local Plan preparation include the
proposed development at Dennybrook further assessment will need to include substantially more
detailed consideration of the mitigation measures required to accommodate travel demands arising
from the potential new settlement and its resultant impacts.
The potential development at Wyboston is not well connected to existing public transport routes nor
will it be to the preferred route option for East-West rail where a new station is expected along the
East Coast Mainline Railway between St Neots and Sandy. Without thorough consideration and
incorporation of sustainable and safe modes of transport connecting the settlement to such
transport hubs, it is likely to result in increased trips being made by private cars. The reliance on the
A1 for transport and the impact of development on the capacity along the A1 is of concern,
particularly regarding the impacts on the Buckden roundabout for which mitigation works are
required in response to locally proposed development. In addition, the potential delays in journey
times arising from increased vehicle movements along the A428 and consequent delays and
congestion within St Neots would detrimentally affect residents and businesses of St Neots. The
impact this would have on air pollution and air quality is particularly important as central St Neots
contains an Air Quality Management Area. Huntingdonshire District Council is concerned that this
could exceed acceptable thresholds of air pollutants and harm the health of Huntingdonshire
residents, this would also be contrary to national policy on air quality and climate change.
The location and quantum of employment floor space within the site are of concern, particularly in
relation to the impact on the vitality and viability of the Established Employment Areas within St
Neots, especially those to the south (Howard Road Industrial Estate, Little End Road/ Alpha Drive
Business Park and Colmworth Business Park). The proposal is highly likely to impact upon the vitality
and viability of existing employment areas within St Neots and careful consideration must be given
to promoting a sustainable and complementary mix of uses within the proposed new settlement
should the proposal move forward.
The proposed new settlement is an extensive predominantly greenfield site comprising land of
highest quality agricultural value. Alternative options which prioritise the use of previously
developed land should be fully explored before this site is included in Bedford’s future development
strategy. The site may have detrimental impacts on the designated Lower Great Ouse River Valley
green infrastructure network opportunity zone (policy AD24 of the Bedford Local Plan to 2030). All
possible avenues to avoid this should be explored before any mitigation options are considered. All
opportunities to deliver biodiversity net gain within the scheme should also be investigated and
secured.
In conclusion, Huntingdonshire District Council have considerable concerns over the long-term
potential scale of the scheme and object to the potential allocation of Wyboston (Dennybrook) as a
strategic scale location for growth based on the significantly detrimental impact on St Neots in terms
of increased demands on infrastructure, proximity of development, substantial landscape impact,
traffic generation, air quality, climate change and detrimental outcomes for Huntingdonshire
residents and businesses.

Object

Representation ID: 8221

Received: 26/09/2021

Respondent: Mr John Leashon

I am most concerned about the proposal to build a new town the size of biggleswade on the edge of Eaton Socon. It makes no sense for the following reasons:
1. It wastes 6 sq. miles of prime farmland – much needed for UK food production. It could produce 23 million loaves/year.
2. It has no ready access for construction traffic.
3. The inhabitants would all shop in St Neots (Cambs)
4. The inhabitants would have to use cars to reach a train station.
5. When added to proposed development in St. Neots it would make town to rival Bedford as hub with station on East Coast Mainline, A1(M) and A421/A14 transport links.
6. Bedford town needs to be kept compact for minimising transport needs, increasing town trade/shopping and ease of energy and services provision.
7. This scheme makes no use of brown sites as demanded by Central Government.

Object

Representation ID: 8359

Received: 03/09/2021

Respondent: Mrs Bernadette Yockney

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Cobholden Site 997
Cobholden is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Duloe, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Object

Representation ID: 8367

Received: 03/09/2021

Respondent: Mr Phillip Yockney

Dennybrook Site 977
Land west of Wyboston (Dennybrook) Site 977
Dennybrook is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Honeydon, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are many nature reserves and listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.

Cobholden Site 997
Cobholden is unsuitable because: there is a risk of coalescence with St Neots, it would engulf Duloe, the location is high quality agricultural land, it is valued as a rural location by its residents, there are no services, the roads are very narrow, it is too far from the new E-W rail station to offer sustainable transport, there are listed buildings and a large development could cause flooding in St Neots. The transport modelling is flawed and underestimates the number of trips.